Renovating a Historic Building? What Business Owners Should Know About ADA Accessibility

Veronica Landau, IIDA, LEED Green Associate, WELL AP

Historic buildings give our communities character but adapting them for modern businesses can present unique challenges. One of the most common misconceptions is that an older or historic building is automatically exempt from the Americans with Disabilities Act (ADA).

It isn't.

Businesses that serve the public generally have accessibility responsibilities regardless of the age of the building.

What Qualifies as a Historic Building?

For purposes of the ADA's historic-building provisions, a qualified historic property is generally one that is listed or eligible for listing in the National Register of Historic Places or is designated historic under applicable state or local law.

Simply being an old building does not necessarily make it a qualified historic property.

Historic properties are still expected to comply with accessibility requirements to the maximum extent feasible. However, the ADA recognizes that certain modifications could threaten or destroy historically significant features. In those specific circumstances, alternative accessibility provisions may be available.

The goal is to balance accessibility with historic preservation—not choose one over the other.

Not Every Renovation Has the Same Accessibility Impact

For a tenant or business owner, it is helpful to think about renovation scopes in three general categories:

1. Minor Maintenance and Cosmetic Work

Painting, wallpapering, reroofing, and similar maintenance generally are not considered alterations under the ADA unless the work affects usability.

That does not necessarily mean an existing business has no other ADA obligations. Places of public accommodation may have separate responsibilities to remove existing architectural barriers when removal is readily achievable.

2. Alterations to Specific Elements or Spaces

Once a renovation changes something that affects usability, the altered elements generally need to meet applicable accessibility requirements to the maximum extent

feasible.

Replacing a doorway, renovating a restroom, changing a service counter, reconfiguring walls, or replacing certain floor surfaces can therefore introduce accessibility requirements within the scope of the project.

A useful rule of thumb is:

If you're changing it, check it for accessibility.

3. Alterations to a Primary Function Area

A primary function area is a space where the major activity of the business occurs—for example, the dining area of a restaurant, customer service area of a business, retail sales floor, or office work area.

When an alteration affects a primary function area, the project can also trigger accessibility improvements along the path of travel or circulation serving that area.

That can include:

• The accessible entrance

• Route from parking or site arrival points

• Interior accessible route

• Restrooms serving the space

• Drinking fountains and certain other amenities, where provided

• 
  

For private businesses subject to ADA Title III, these additional path-of-travel improvements are required to the extent they are not disproportionate or outweigh the cost of the primary-function alteration. Under the federal ADA regulations, costs exceeding 20% of the cost of the alteration to the primary function area are considered disproportionate.

Importantly, the 20% rule is not a blanket exemption from ADA compliance and does not mean that a business can simply budget 20% of every renovation for accessibility. If you project is experiencing this issue, ADA has a list of priorities of what accessible features need to be addressed up to the 20% cost.

Why This Matters Before You Sign a Lease

A beautiful historic storefront or office can be an excellent home for a business—but existing conditions can have significant implications for your renovation budget.

A few inches at an entrance, an inaccessible restroom, narrow circulation, changes in floor elevation, or an existing doorway may affect what can realistically be accomplished within the space.

Before committing to a lease, consider having the property evaluated for:

• Existing accessibility conditions

• Proposed alterations and their effects

• Accessible entrances and routes

• Restroom accessibility

• Changes in floor elevation

• Door and corridor clearances

• Service and transaction areas

• Historic features that may limit potential modifications

• Applicable state and local accessibility requirements

  
  

Understanding these conditions before design begins allows accessibility to become part of the project strategy rather than an unexpected problem during permitting or construction.

Commercial Spaces Designed with Intention

Formation Interiors incorporates accessibility into commercial space planning from the beginning. Through test fits, existing-condition reviews, ADA-informed planning, and permit construction documentation, we help business owners understand how an existing building can support their operations before significant design and construction decisions are made.

Considering a historic building for your business? Let's evaluate the space before you commit to the renovation. Contact Formation Interiors!

This article provides general educational information and is not legal or code-compliance advice. Accessibility requirements vary based on project scope, building conditions, occupancy and jurisdiction.